“Week by week, month by month and year by year the Bureau of Land Management (BLM) chisels away at what few herds of wild horses and burros remain on public lands while giving more and more concessions to welfare grazing interests. While screaming that they have no money nor room for former free equines the BLM announced last week that they are going to rip yet another 2,500 equines from their rightful homes and virtually “zero out” or totally destroy several long standing Wyoming herds.

Equine photographer, and Director of Field Documentation for Wild Horse Freedom Federation, Carol Walker, has taken the time to put the the math to the BLM schedule and sheds light on a very serious situation in her latest blog post. Please check back often as we will attempt to keep you abreast of this rapidly developing story as the future well being of thousands of wild equines hangs in the balance as the BLM dances with the law and climbs into bed with private, profiteering grazing interests.” ~ R.T. Fitch

Mares rounded up in Salt Wells Creek in December 2013 ~ photo by Carol Walker

This is despite having just rounded up and removed 586 wild horses from Salt Wells Creek and Adobe Town in December 2013.

Looking at the numbers provided by the BLM, Great Divide Basin will be virtually zeroed out after this roundup and removal. The AML for the area is 415-600 wild horses. At their May 2013 count they said there were 439 horses and they estimated that there would be 579 in the summer of 2014. Removing 541 would be almost all, if not all, of them.

In Salt Wells Creek, the AML is 251-365. In their projected estimate before the 2013 roundup the BLM said there were 823 wild horses, they removed 586, and they plan to remove 228. Even estimating a 20% population increase this year, this would bring the population below low AML.

In Adobe Town, the AML is 610-800 wild horses. The BLM projected the population to be 624 in 2013, they removed 14 in 2013 and they plan to remove 177, Even estimating a 20% increase in population this year, this would bring the population below low AML.

Currently, the Resource Management Plans for both the Rock Springs and Rawlins Areas are being revised. It is during the Resource Management Revision process that AML can be changed for herd management areas and herd management areas can be changed to herd areas, allowing them to be zeroed out. This process has NOT happened yet…(CONTINUED)

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I bet the dick heads got all that they wanted from the horses and money. I bet that they hid some of the horses so they can sell from there own hands. they must have some horses hid. go take a look on there farms and see what they have to hid. I told my grandfather he could not it when he passed. to enjoy what he had in this life. they are so tight there balls squeak. we never had anything give to us. I’m glad I worked for what I have. with my own hands. and so did my dad and mom. I glad when I go I can rest in piece. cause I will hunt them so will the ones they killed. when they pass there soles will never rest. they made there own hell.

1. I live in Cheyenne, Wyoming. I am a former Bureau of Land Management
(“BLM”) official with extensive experience in the Rawlins and Rock Springs Districts in
Wyoming and intimate familiarity with the public lands under BLM management in those areas.
I have reviewed the consent decree proposed by BLM and the Rock Springs Grazing Association
(“RSGA”) in this case and provide this declaration based on my longstanding knowledge of, and
management of, wild horses and livestock grazing in the Rock Springs and Rawlins Districts.
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2. I grew up in Pine Bluffs, Wyoming with a livestock and farming background,
served in the Marines for four years, and then owned a livestock business from 1952-1958. I
enrolled in college in 1958, studying range management. From 1960-1961, BLM hired me to
assist with collecting field data for vegetation assessments and carrying capacity surveys related
to livestock and wild horses. These surveys were conducted in the Lander, Kemmerer, and
Rawlins Districts. When I graduated in 1962, BLM hired me full-time to serve in the Rawlins
District in Wyoming, where most of my work focused on grazing management involving sheep,
cattle, and wild horses. From 1968-1972, I was Area Manager of the Baggs-Great Divide
Resource Area in the Rawlins District. In 1971, the Wild Free-Roaming Horses and Burros Act
was enacted, and in the spring of 1972, on behalf of BLM, I conducted the first aerial survey of
wild horses in Wyoming, recording the number of horses and designating the Herd Management
Areas (“HMAs”) for the Rawlins District. After a stint as an Area Manager with BLM’s
Albuquerque, New Mexico office, in 1975 I took over as the Chief of Planning and
Environmental Analysis in BLM’s Rock Springs District for three years. I was the lead on all
planning and environmental assessments. During that time, I also served as the Acting Area
Manager of the Salt Wells Resource Area, which is located in the Rock Springs District. In
1979, BLM transferred me to its Denver Service Center to serve as the Team Leader in creating
the agency’s automated process for data collection. I received an excellence of service award
from the Secretary of the Interior commending me for my work as a Team Leader. In 1982, I
became the Head of Automation in BLM’s Cheyenne office, where I managed and implemented
the data collection and processing of various systems related to BLM programs. I retired from
BLM in 1986, and have stayed very involved in the issue of wild horse and livestock
management on BLM lands in Wyoming, and have written articles about the issue in local and
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other newspaper outlets. I have won various journalistic awards, including a Presidential award,
for my coverage of conservation districts in Wyoming. Along with a partner, I operated a tour
business (called Backcountry Tours) for six years, taking various groups into wild places in
Wyoming – without a doubt wild horses were the most popular thing to see on a tour, in large
part due to their cultural and historical value. I also served six years on the governor’s non-point
source water quality task force.

3. Based on my longstanding knowledge of wild horse and livestock management in
the Rawlins and Rock Springs Districts, and in the Wyoming Checkerboard in particular, I am
very concerned about BLM’s agreement with RSGA, embodied in the proposed Consent Decree
they have filed in this case, under which BLM would remove all wild horses located on RSGA’s
private lands on the Wyoming Checkerboard.
4. The Checkerboard is governed by an exchange of use agreement between the
federal government and private parties such as RSGA. However, due to state laws, property
lines, and intermingled lands, it is impossible to fence the lands of the Wyoming Checkerboard,
which means that both the wild horses and the livestock that graze there roam freely between
public and private lands on the Checkerboard without any physical barriers. For this reason, it is
illogical for BLM to commit to removing wild horses that are on the “private” lands RSGA owns
or leases because those same horses are likely to be on public BLM lands (for example, the Salt
Wells, Adobe Town, Great Divide, and White Mountains HMAs) earlier in that same day or
later that same evening. Essentially, in contrast to other areas of the country where wild horses
still exist, on the Wyoming Checkerborad there is no way to distinguish between horses on
“private” lands and those on public lands, and therefore it would be unprecedented, and indeed
impossible for BLM to contend that it is removing all horses on RSGA’s “private” lands at any
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given time of the year, month, or day, considering that those horses would only be on the strictly
“private” lands very temporarily and intermittently on any particular day .

5. Another major concern with BLM’s agreement to remove all horses from the
private lands of the Wyoming Checkerboard is that BLM is undermining the laws that apply to
the Checkerboard, and wild horse management in general, which I implemented during my time
as a BLM official. Traditionally, BLM officials (myself included) have understood that,
pursuant to the Wild Horse Act, wild horses have a right to use BLM lands, so long as their
population numbers do not cause unacceptable damage to vegetation or other resources. In stark
contrast, however, livestock (sheep and cattle) have no similar right to use BLM lands; rather,
livestock owners may be granted the privilege of using BLM lands for livestock grazing pursuant
to a grazing permit that is granted by BLM under the Taylor Grazing Act, but that privilege can
be revoked, modified, or amended by BLM for various reasons, including for damage to
vegetation or other resources caused by livestock, or due to sparse forage available to sustain
livestock after wild horses are accounted for. BLM’s tentative agreement here does the opposite
and instead prioritizes livestock over wild horses, by proposing to remove hundreds of wild
horses from the Wyoming Checkerboard without reducing livestock numbers – which, in my
view, is contrary to the laws governing BLM’s actions as those mandates were explained to me
and administered during the decades that I was a BLM official.
6. While I do not agree with every management action taken by BLM over the
years in the Rock Springs District, I can attest – based on my longstanding employment with
BLM and my active monitoring of the agency’s activities during retirement – that BLM has
generally proven capable of removing wild horses in the Rock Springs District, including by
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responding to emergency situations when needed and removing horses when necessary due to
resource damage.

7. Considering that wild horses exhibit different foraging patterns and movement
patterns than sheep and cattle, and also than big game such as antelope and elk, no sound
biological basis exists for permanently removing wild horses from the Wyoming Checkerboard
at this time. In particular, wild horses tend to hang out in the uplands at a greater distance from
water sources until they come to briefly drink water every day or two, whereas livestock
congregate near water sources and riparian habitat causing concentrated damage to vegetation
and soil. For this reason, the impacts of wild horses are far less noticeable on the Checkerboard
than impacts from livestock.
8. In addition, because livestock tend to eat somewhat different forage than wild
horses (horses tend to eat coarser vegetation such as Canadian wild rye and other bunch grasses,
whereas cattle and sheep mostly eat softer grasses), there is no justification to remove wild
horses on the basis that insufficient forage exists to support the current population of wild horses.
Also, because cattle and sheep have no front teeth on the front part of their upper jaws, they tend
to pull and tear grasses or other forage out by the root causing some long-term damage to
vegetation, whereas wild horses, which have front teeth on both their front upper and lower jaws,
act more like a lawnmower and just clip the grass or forage (leaving the root uninjured), allowing
the vegetation to quickly grow back. These differences are extremely significant because if there
were a need to reduce the use of these BLM lands by animals to preserve these public lands, it
might be cattle and sheep – not wild horses – that should be reduced to gain the most benefit for
the lands, and which is why BLM, during my time as an agency official, focused on reducing
livestock grazing.
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9. BLM’s agreement with RSGA states that RSGA’s conservation plan limited
livestock grazing, primarily by sheep, to the winter months to provide sufficient winter forage.
This is a good example of “multiple use” management, since wild horses and sheep have very
little competition for the forage they consume and the seasons during which they use parts of the
Checkerboard. During winter, sheep use the high deserts and horses utilize the uplands and
breaks (i.e., different locations) for forage and protection. During the summer, when sheep are
not present, wild horses use various landscapes on the Checkerboard. This multiple use should
continue for the benefit of the livestock, the wild horses, and the public and private lands
involved.
10. I am also very concerned about BLM’s agreement with RSGA to permanently
zero out the Salt Wells HMA and the Divide Basin HMA, leaving no wild horses in those areas
that have long contained wild horses. I have been to fifteen of the sixteen HMAs in Wyoming,
and to my knowledge none has ever been zeroed out by BLM. It is my view, based on
everything I know about these areas and the way these public lands are used by wild horses and
livestock, that BLM has no biological or ecological basis for zeroing out a herd of wild horses in
an HMA that existed at the time the wild horse statute was passed in 1971, as is the case with
both the Salt Wells and Divide Basin HMAs. And, again, because the wild horses have a
statutory right to be there, whereas livestock only have a privilege that can be revoked at any
time by BLM, there also is no authority or precedent, to my knowledge, for the agency to zero
out these two longstanding wild horse herds simply to appease private livestock grazers.
11. The zeroing out of wild horses in the Salt Wells and Divide Basin HMAs is also
concerning because it would mean that, in those two longstanding HMAs, there would no longer
be the “multiple use” of these public lands as required by both the Wild Horse Act and the
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Federal Land Policy and Management Act. Currently, while there are other uses of this public
land, such as by wildlife, hunters, and recreational users, the two primary uses in those HMAs
are by wild horses and livestock. If BLM proceeds with its agreement with RSGA to zero out
wild horses in those HMAs, the only major use remaining would be livestock use, meaning that
there would be no multiple use of those BLM lands. Not only will that potentially undermine the
laws that BLM officials must implement here, but it has practical adverse effects on the
resources – multiple use is very beneficial for the environment, and particularly for sensitive
vegetation, because different users (e.g., livestock, wild horses) use the lands and vegetation in
different ways. When that is eliminated, the resources are subjected to an unnatural use of the
lands which can cause severe long-term damage to the vegetation. As a result, zeroing out these
herds would likely be devastating for the vegetation in these two HMAs, because livestock
would be by far the predominant use in this area.

12. Turning the White Mountain HMA into a non-reproducing herd, as the agreement
between BLM and RSGA proposes to do, is also a farce, and violates the meaning of a wild and
free-roaming animal. This is essentially a slow-motion zeroing out of this HMA, and is
inconsistent with any wild horse management approach I am familiar with that BLM has
implemented on public lands.
– 7

Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true
and correct.